IR 05000354/1986037

Insp Rept 50-354/86-37 on 860730-0802.No Violations Noted. Major Areas Inspected:Licensee Action on Previous Findings, Organization & Staffing,Communications,Audits,Alara & High Radiation Area Access Control

ML20206P136
Person / Time
Site:	Hope Creek
Issue date:	08/19/1986
From:	Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206P134	List: IR 05000354/1986037 ML20206P130
References
50-354-86-37, NUDOCS 8608270107
Download: ML20206P136 (10)

Text

'

..

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

' Report N /86-37 Docket N License N NPF-50 Category B Licensee: Public Service Electric and Gas C Park Plaza 17 C Newark, New Jersey 07101 Facility Name: Hope Creek Generating Station Inspection At: Hancocks Bridge, New Jersey Inspection Conducted: July 30, 1986 through August 2, 1986 Inspectors: 0 L tdd R. L. Nimitz, Senior Radfation Specialist B$lftk%

date Approved by: W. S /A _IM M. Shanba~ky, Chief,~ Facilit;ipt f[/9k[

date

~

Radiation Protection Section Inspection Summary: Inspection on July 30 - August 2, 1986. Report N /86-3 Areas Inspected: Routine, unannouncad inspection of the following: licensee action on previous findings; organization and' staffing; communications, audits, ALARA; high radiation area access cor. trol; startup surveys; and in-field radio-logical control ,

Results: No violations were identifie .

8608270107 860820 .

PDR ADOCK 05000354 .

G PDR

-

(.

.

DETAILS 1.0 Individuals Contacted 1.1 Public Service Electric and Gas

,

• R. S. Salvesen, General Manager

• P. M. Kreshna, Assistant to General Manager

• J. R. Lovell, Radiation Protection and Chemistry Manager

• J. J. Molner, Senior Radiation Protection Supervisor

• J. L. Kotsch, Principal Engineer

• P. Preston, Manager, Licensing and Regulation

• J. N. Leech, Principal Engineer . Licensing

• R. T. Griffith, Principal Engineer - QA 1.2 Nuclear Regulatory Commission

• R. W. Borchardt, Senior Resident Inspector, Hope Creek I

• denotes those individuals attending the exit meeting on August 1, 198 The inspector also contacted other individual . Inspection Purpose The' purpose of this inspection was to review the following Radiological Controls Program elements and ascertain their- status and/or conformance with licensee commitments or applicable regulatory requirements:

Radiological Controls Group Organization and Staffing I *

Radiological Controls Department intra and inter departmental

communication , <1 j

• Audits '

)

ALARA Program ,

i * High Radiation Area Controls  ;

'

Startup Radiation Survey Program

Adequacy, Effectiveness, and Implementation of In-field Radiological Controls.

! i

!

!

!

-

.

t

!

- = , , _ - , ,_ _ , - - , - _ - - - - - . _ . . . - __-. _ - - - - _ . -- , _ - - _ , . . , - - - - - ~ - . ~ .

---

(-

.

,

3.0 Licensee Action on previous Findings 3.1 Closed (Followup Item) (50-354/86-07-06)

Licensee to upgrade internal exposure assessment and control program to address deficiencies identified in inspection report 50-354/86-2 The licensee upgraded the internal exposure assessment and control progran to address the previously identified deficiencies. Adequate procedure changes were made where appropriat .2 Open (Followup Item) (50-354/86-07-02)

Licensee to address technical deficiencies in his airborne radio-activity sampling and analysis program. The licensee previously addressed the majority of the deficiencies of this item. The following matter remains open:

• Incorporation of appropriate sample analyses results correction factors to address filter Icading. This matter is particularly important relative to analysis of samples for alpha radio-

'

activit .3 Open (Followup Item) (50-354/86-07-12)

, Licensee to review and evaluate adequacy of supplied beta dosimetr The licensee is currently reviewing the adequacy of his beta dosi-metr .4 Open (Follow-up Item) (50-354/86-07-03)

Licensee to review and evaluate the adequacy of stand-up frisker The licensee is currently 'reviewirg and evaluating the adequacy of his stand-up frisker .0 Organization / Staffing The inspector reviewed the organization and staffing of the Radiological Controls Organization with respect to Technical Specification 6.2,

" Organization".

~

Within the scope of this review no violations were identifie Within the scope of this review, the following item needing licensee's attention was identified: .

Update administration procedures to reflect recent radiological controls organization changes and personnel responsibilitie e f

- .- - ,- _

- - . _ . - _ _ _ , . , . _ _ ~ - - - _ ..

.

.

5.0 Communications (Radiological Controls)

The inspector reviewed the adequacy and effectiveness of inter anc intra departmental communication Within the scope of this review no unacceptable conditions were rot? The licensee's Radiological Controls group exhibited generally effe:tive communications. The following positive attributes were:

.

Shift turnovers were performed in a generally effective manne * Shift radiological controls personnel attended coerations shift turnover *

Appropriate radiological control personnel attended major plant staff meeting *

Radiological control personnel were integrated into planning and scheduling and were aware of upcoming wor Item for Improvement

• Clearly describe responsibilities of contractor H.P. interface with HP grou .0 Audits The inspector reviewed the licensee's audit program with respect to criteria contained in Technical Specifications: The following audits /

,

surveillances were reviewed:

Audits /Surveillances

HC-85-193, Surveillance Audit Radwaste Shipment

• HC-85-192, Radwaste Operations'

• HC-86-084, Radwaste Operation /Decont Procedure

• HC-86-083, Radwaste Operation / Bead and Powdered Resin Transfer

NQA Audit 85-048 Others

• INPO, July 1985 Audit

• General Dynamics Audits (1986)

Radiation Protection Services Audits

• ANI Audit, March 1986 .

.

.

The purpose of this review was to determine the following:

• the licensee complied with applicable requirements a audit findings were resolved in a timely and acceptable nanne Findings Within the scope of this review, the following was identified:

• The NQA audits (e.g.85-048) of Radiological Control Group activities appeared to be ccmpliance oriented audits. The audits did not ex-amine program or procedure adequac Consequently, the inspector was unable to determine the effectiveness of the audi * The Radiation Protection Services Group performed assistance assessments of the hope Creek Radiation Protection Program. The inspector was unable to identify any formal mechanism whereby RPS tracked their findings to resolutie *

The inspector was unable to identify a mechanism requiring the site radiation protection organization to respond to the findings identified by the corporate Radiation Protection Services Grou *

The licensee hassobtained contractor support to audit the Hope Creek Radiation Protection Progtam. Inspection review of audit findings irdicate a nember of findings were identified. However, no program / ;

methodology was in place to track significant findings to resolutio The licensee subsequently established a method to track significant findings to resolutio The adequacy, effectiveness, and resolution of audit findings will be reviewed during a subsequent inspection (50-354/86-37-01).

7. High Radiation Area Controls The inspector reviewed the adequacy and effectiveness of the licensee's High Radiation area controls. The review was with respect to criteria contained in Technical Specifications and &pplicable procedures.,

The purpose of this review was to determine the following:

• were High Radiation Areas present

were present High Radiation Areas properly posted, barricaded and locked if required

were access controls established and adequate The evaluation of the licensee's performance was based on discussion with personnel, review of documents, observation during tours by the inspecto ..

. ___ _ .-_

.

.

Within the scope of this review, no violations were identified. However, the following matters needing licensee's attertion were identified:

'

'

• The radiation work permit procedure did not provide adequate guidance relative to clearly describing the method of high radiation area accest control to be utilized. (e.g. continuous radiological control coverage, use of alarming dosimeters)

• The procedures for high radiation area access control did not clearly define / describe terms to be written on the radiation work permit to implement the periodic surveillance requirements of Technical Specifications (e.g., continuous, intermittent). These terms were not adequately define *

Administrative control of all High Radiation Area Access Points is not consistent with Technical Specification 6.12 in that Security personnel have master keys to these area (NOTE: No High Radiation Areas were found to be inadequately controlled. The Drywell was the only area which exhibited dose rates requiring access contro This area was adequately controlled. Security personnel could not gain sole access to this area with their key.)

Procedures which describe access control to the TIP room did not address access precautions relative to potential withdrawal of TIPS on an auto isolation signa *

The alarm location and area posting for the TIP drives (outside) did not ensure personnel would respond properly (i.t. evacuate area) if an activated TIP is inadvertently withdrawn into the drive are Licensee representatives indicated that access control to high radiation areas (e.g. Drywell) will be upgraded prior to startup. Also the licensee indicated that the area around the TIPS vill be posted to alert personnel of actions to be taken in the event of an alarm. This will also be completed prior to the startu The licensee's action on the above high radiation area control matters will be reviewed during a subsequent inspection (50-354/86-37-01).

Within the scope of this review, the following item for improvement was identifie '

Consideration should be given to locking those areas that normally exhibit transient and unusually high radiation areas during routine operations but currently, due to low power levels, ldo not yet exhibit radiation levels of significance, a

>

C_.___ __________.__________________m

._ _

.

.

,

8.0 ALARA The inspector -eviewed the adequacy and implementation of selected elements of the licensee's ALARA Program. The review was with respect to criteria contained in the following:

Reguletory Guide 8.8, "Information Relevant to Ensuring That Occupationt.1 Radiation Exposures at Nuclear Power Stations Will Be As Low As is Reasonably Achievable",

Regulatory Guide 8.10, " Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Is Reasonab!y Achievable" t

• Procedure AP-7, "ALARA Program"

'

• Procedure RP-TI-22-05, "ALARA Reviews"

PSE&G ALARA Manual The following matters were reviewed:

program establishment and implementation a goals development

'

The following positive attributes were noted:

,

*

The licensee has placed radiological controls,petsonnel in the planning and scheduling group. These individuals provide an i

interface between licensee's radiological control group and the

.

planning and scheduling group.

'

The licensee has initiated action to perform Zinc injection into the primary syste The injection of Zinc has been shown to reduce radiation levels from primary system pipin *

The licensee plans to send station personnel, including radiological controls personnel, to Japan to examine remote tools for Control Rod Drive work and other wor *

The licensee previously sent personnel to Sweden to examine Radio-logical Controls and methods for radiation exposure control.

The following matters needing licensee attention was identified

improvements are needed in the establishment and implementation of

! an ALARA Goals Program.

,

ALARA controls for identifying / initiating reviews of repotitive jobs

, in a timely manner need upgrading, k

- .- -

_

.

.

• On going job review criteria needs upgrading. Criteria should provide clear guidance for performing additional review of on going jobs resulting from excess exposure, man-hours or dose rate .0 Start-Up Survey Program The inspector reviewed the licensee's Start-up Survey Program with respect to criteria contained in the following:

• Final Safety Analysis Repor * 10 CFR 20, " Standards for Protection Against Radiation".

• Applicable Licensee procedure *

ANSI /ANS - 6.3.1, 1980, " Program for Testing Radiation Shields in Light Water Reactors",

• ANSI-N323, 1978, " Radiation Protection Instrumentation Test and Calibration",

Regulatory Guide 1.68, November 1978 "Preoperational and Start-up Test Program for Water-Cooled Power Reactors (LWR)".

The purpcse of the review was to determine the following:

Appropriate procedures-were in place and were being use * Tests were performed on schedul *

Test results were properly reviewe . .

Appropriate radiation survey instrumentation was used and was properly calibrate *

Personnel performing surveys were provided proper personnel dosimetr Within the scope of this review, no violations were identified. However,

~

the following item needing licensee attention was identified:

The licensee is not performing source checks of the neutron survey meters prior to each use as recommended by appropriate industry standards. The licensee should review the acceptability of the practice and provide appropriate source checks'if deemed necessar .0 Routine Radiological Controls The inspector reviewed the implementation, adequacy, and effectiveness of in plant radiological controls. The review was with respect to applicable Technical Specifications and procedures. The following matters were reviewed.

- ___ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ -

.

.

posting, barricading and access control (as appropriate)

• implementation of procedural requirements

• use of RWPs a selection, qualification and training of radiological controls personnel providing responsible radiological oversight

=

contamination controls

• performance of proper radiological surveys The evaluation of the licensee's performance in this area was based on:

discussion with personnel; inspector observations of on going work; and review of documentatio No violations were identified. The following matters needing licensee attention were identified: '

Appropriate radiation survey instrumentation was not consistently used by radiation protection personnel. Dersonnel were observed using GM type survey instruments when air ionization chamber type-instruments wpre appropriate for use. One technician was noted to make repeate,c entries into an area (Reactor Water Cleanup Pump Room)

to perform additional measurements, due to lack of appropriate survey instrument *

Beta radiation surveys maasurements were not performed in a consistent manne *

Radiation suryey documentation was found (in some instances) to be

.

confusing, particularly with respect to location and type of measure-ment actually performed (e.g. contact or waist-level; beta or gamma)

Supervisory review of survey data had not identified survey deficiencie The inspector noted that the use of le'ss than optimum instrumentation to perform radiation survey measurements and the less than acceptable quality of documentation of radiation survey results indicate a need for improved supervisory oversight of these area Within the scope of this review, the following item for improvement was identified:

,

. - . . - . . . .

.

.

• Provide an appropriate level of guidance (to technicians manning

,

" remote" access control points to ensure these individuals clearly understand their minimum required duties at ttese remote locations

'

(e.g. Drywell access control point). Consideration should be given to establishing remote Access Control Point procedure '

11.0 Exit Meeting The inspector met with licensee representatives (denoted in Section 1) at s

'

the conclusion of the inspection on August 1, 1986. The inspector

! summarized the purpose, scope and findings of the inspection. No written -

material was provided to the license The inspector discussed some of the deficiencies in the area of in plant radiological controls. The inspector indicated these deficiencies ( use of inappropriate survey instrumentation, lack of beta radiation surveys and confusing documentation of radiation survey results) appear to indicate the need for additional supervisory oversight of in-field

.

wor .

!

i l

i

i

i

!

I

I

'

,

l

-

- - . _ . - - - _ - . .-- .

. _ - - . . - . - _ _ , _ _ - _ _ - - . _ . . .-